RF 11B Dividends paid by companies in certain situations

The rate of NRWT payable on a payment of non-resident passive income in the form of a dividend paid by a company to a non-resident is—

(a)

to the extent to which the payment is a fully-imputed dividend, 0% if—

(i)

the non-resident has a direct voting interest in the company of 10% or more:

(ii)

the non-resident does not have a direct voting interest in the company of 10% or more and, in the absence of this section, the post-treaty tax rate for the dividend would be less than 15% if no imputation credits were attached to the payment:

(b)

to the extent to which the payment is not a fully-imputed dividend, the post-treaty tax rate for the dividend that, in the absence of this section, would apply if no imputation credits were attached to the payment.

Defined in this Act: company, direct voting interest, dividend, fully imputed, imputation credits, non-resident, non-resident passive income, NRWT, pay, post-treaty tax rate

Section RF 11B: replaced (with effect on 1 February 2010), on 2 November 2012, by section 152 of the Taxation (Annual Rates, Returns Filing, and Remedial Matters) Act 2012 (2012 No 88).

Section RF 11B list of defined terms fully imputed: inserted, on 24 February 2016, by section 243 of the Taxation (Annual Rates for 2015–16, Research and Development, and Remedial Matters) Act 2016 (2016 No 1).

Section RF 11B list of defined terms fully-imputed dividend: repealed, on 24 February 2016, by section 243 of the Taxation (Annual Rates for 2015–16, Research and Development, and Remedial Matters) Act 2016 (2016 No 1).